On 7 July 2011, the Federal Energy Regulatory Commission (FERC) issued an order approving a stipulation and consent agreement between the Office of Enforcement (Enforcement), the North American Electric Reliability Corporation (NERC), and the Western Electric Coordinating Council (WECC). The stipulation and consent agreement stem from an investigation into possible violations of Reliability Standards related to a Bulk Electric System disturbance in Utah on 14 February 2008. WECC has agreed to pay a US$350,000 penalty and to revise its compliance program. The incident occurred when the Pacific Northwest Security Coordinator (PNSC) was Reliability Coordinator, but WECC has now assumed PNSC's Reliability Coordinator function, including all of PNSC's obligations and liabilities.
The order is important for a number of reasons. The order represents only the second finalized FERC investigation into violations of Reliability Standards and involves a Regional Entity functioning in its capacity as Reliability Coordinator. The order and settlement do not include a statement as to how WECC will pay for the US$350,000 penalty, nor do they include a statement regarding the applicability of penalty guidelines. Finally, the penalty seems low given that Florida Power and Light Company paid a US$25 million fine in connection with the Flagami incident (although the Florida Reliability Coordinating Council, in its role as Reliability Coordinator, paid only a US$350,000 fine in connection with the Flagami incident).
On 14 February 2008, a fault occurred in the PacifiCorp East Balancing Authority Area (PacifiCorp East) in the PNSC Reliability Coordinator Area, causing a loss of approximately 2,800 MW of generation and requiring PacifiCorp East to shed 183 MW of firm load. Immediately after the disturbance began at 09:16 Mountain Standard Time, PacifiCorp East's Area Control Error (ACE) was significantly negative at approximately -2,400 MW. Because ACE measures the power balance at interties between Balancing Authority Areas (BAAs), this indicates that PacifiCorp East was relying on other BAAs to maintain its own operations. The Disturbance Control Standard, BAL-002-0, R4, required PacifiCorp East to restore its ACE within 15 minutes (i.e., by 09:31). PNSC instructed PacifiCorp to restore its ACE at 09:44.
PacifiCorp first restored its ACE to 0 at 10:00, 44 minutes after the incident began. PNSC issued an Energy Emergency Alert-2 (EEA-2), but then effectively withdrew that alert (upon PacifiCorp's request) by issuing an EEA-0 that indicated normal operations. At 10:15, however, PacifiCorp's ACE became negative again as power from the Northwest Power Pool was withdrawn. PacifiCorp issued a second request for emergency power from the Northwest Power Pool but then mistakenly withdrew that request. PacifiCorp needed to shed firm load again at 10:44 and did not restore ACE to zero until 11:00.
Violations of Reliability Standards
An investigation by FERC and NERC found that PNSC violated nine requirements of five Reliability Standards. PNSC violated Reliability Standards by:
- Failing to respond properly to the disturbance (Reliability Standards IRO-005-1, Requirement R11; IRO-005-1, Requirement R8; EOP-002-2, Requirement R1; IRO-001-1, Requirement R3; and IRO-005-1, Requirement R13).
- Failing to issue proper Energy Emergency Alerts (Reliability Standard EOP-002-2, Requirement R8).
- Failing to issue a proper three-step directive to shed load (Reliability Standard COM-002-2, Requirement R2).
- Lacking awareness of a Special Protection System (Reliability Standard IRO-005-1, Requirement R12).
- Failing to have procedures in place for how PNSC Reliability Coordinators should respond when PNSC's Real-Time Contingency Analysis tool did not function (Reliability Standard IRO-002-1, Requirement R9).
Penalty and stipulation
WECC agreed to pay a US$350,000 penalty that will be split equally between NERC and the United States Treasury.
WECC also stipulated that it will implement "Reliability Enhancement Measures." These measures include improved training, procedure enhancements, and updated tools to ensure that:
- Reliability Coordinators will promptly direct Balancing Authorities to comply with the Disturbance Control Standard.
- Reliability Coordinators will understand capacity and energy emergency plans.
- WECC will run a prompt contingency analysis even if its real-time contingency analysis program does not run.
- Reliability Coordinators will issue proper three-step directives.
- WECC will create a "responsibility to act" culture among its Reliability Coordinators.
- WECC's system modeling and other tools will account for the effects of Special Protection Schemes.
- Reliability Coordinators will better understand the Northwest Power Pool reserve sharing program.
- Reliability Coordinators will better understand the Balancing Authorities' reserves, the ability of Balancing Authorities to maintain those reserves, and the responsibility of Reliability Coordinators to act when a Balancing Authority lacks reserves.
- WECC will implement procedures to address emergencies like that which occurred on 14 February 2008.